Canadian Transfer Pricing Resources

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transferpricing.ca

YOUR ANSWER TO ALL CANADIAN TRANSFER PRICING QUESTIONS

RESOURCES

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Income Tax Act, Information Bulletins, Information Circulars and Guidelines as provided by the Canada Customs and Revenue Agency:

Income Tax Act Section 247

IC 87-2R International Transfer Pricing

IC 94-4R International Transfer Pricing: Advance Pricing Arrangements (APAs)

IC 71-17R4 Requests for Competent Authority Considerations Under Mutual Agreement Procedures in Income Tax Conventions

IT 177-R2 Permanent Establishment of a Corporation in a Province and of a Foreign Enterprise in Canada

Guidelines for Treaty-Based Waivers Involving Regulation 105 Withholding

RC 4213 - Your Rights in Your Dealings with the Canada Customs and Revenue Agency

Canada Customs and Revenue Agency Forms:

T106 - Summary and Supplementary Form - Information Return of Non-Arm's Length Transactions with Non-Residents

T1134A - Information Return Relating to Foreign Affiliates That Are Not Controlled Affiliates

T1134B - Information Return Relating to Controlled Foreign Affiliates

T1135 - Foreign Income Verification Statement

T1141 - Information Return in Respect of Transfers or Loans to a Non-Resident Trust

T1142 - Information Return in Respect of Distributions from and Indebtedness to a Non-Resident Trust

Canadian Treaties as provided by Ministry of Finance

Canada - U.S. Tax Convention

Other

PATA Transfer Pricing Documentation Package

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